Vulcan Materials Co. v. Commissioner
United States Tax Court
P was a 48-percent shareholder and two other U.S. corporations were each 10-percent shareholders in TVCL, a Saudi Arabian corporation, the remaining shareholders being Saudi Arabian nationals. The Saudi Arabian income tax was imposed only on the income allocable to the 68-percent interest of the U.S. shareholders, the Saudi Arabian shareholders being subjected to a capital tax.
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P was a 48-percent shareholder and two other U.S. corporations were each 10-percent shareholders in TVCL, a Saudi Arabian corporation, the remaining shareholders being Saudi Arabian nationals. The Saudi Arabian income tax was imposed only on the income allocable to the 68-percent interest of the U.S. shareholders, the Saudi Arabian shareholders being subjected to a capital tax. Held, the term "accumulated profits" in the denominator of the fraction utilized to determine the indirect foreign tax credit under sec. 902, I.R.C., includes only that portion of such profits of TVCL allocable to the…
1Opinion of the Court
Vulcan Materials Company and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Vulcan Materials Co. v. Commissioner
Docket No. 11680-88
United States Tax Court
96 T.C. 410; 1991 U.S. Tax Ct. LEXIS 13; 96 T.C. No. 13;
March 5, 1991, Filed
Decision will be entered for the petitioner.
P was a 48-percent shareholder and two other U.S. corporations were each 10-percent shareholders in TVCL, a Saudi Arabian corporation, the remaining shareholders being Saudi Arabian nationals. The Saudi Arabian income tax was imposed only on the income allocable to the 68-percent interest of the…
2Cases cited13 opinions
- United States v. Jefferson Electric Manufacturing Co.Supreme Court of the United States · 1934
- Biddle v. CommissionerSupreme Court of the United States · 1938
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Stubbs, Overbeck & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1971
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
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